20210625IPC to Staff 18-23 - Amended.pdf

DONOVAN E. WALKER
Lead Counsel
[e-mail]

June 25, 2021

VIA ELECTRONIC MAIL

Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 West Chinden Blvd., Building 8
Suite 201-A
Boise, Idaho 83714

Re: Case No. IPC-E-21-09
Idaho Power Company’s Application for Capacity Deficiency To Be Utilized
For Avoided Cost Calculations

Dear Ms. Noriyuki:

Attached for electronic filing is Idaho Power Company’s Response to the Amended
Third Production Requests of the Commission Staff in the above entitled matter.

If you have any questions about the attached documents, please do not hesitate
to contact me.

Very truly yours,
Donovan E. Walker

DEW:cld
Enclosures
RECEIVED
2021June 25, PM 2:14
IDAHO PUBLIC
UTILITIES COMMISSION
IDAHO POWER COMPANY’S RESPONSE TO THE AMENDED THIRD PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 1
DONOVAN E. WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]

Attorney for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF IDAHO POWER
COMPANY’S APPLICATION FOR
APPROVAL OF THE CAPACITY
DEFICIENCY TO BE UTILIZED FOR
AVOIDED COST CALCULATIONS.
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CASE NO. IPC-E-21-09

IDAHO POWER COMPANY’S
RESPONSE TO THE AMENDED
THIRD PRODUCTION REQUEST
OF THE COMMISSION STAFF

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to the Amended Third Production Request of the Commission Staff to Idaho
Power Company dated June 16, 2021, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO THE AMENDED THIRD PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 2
REQUEST NO. 18: Should the load and resource balance (“L&R”) and the
capacity deficiency date filed in Case No. IPC-E-21-09 be updated to include the following
items? In the Company’s response, please explain why the deficit date should or should
not change by considering each item below:
a. The growth in peak loads referenced in the Company’s Notice of Intent (“NOI”)
driving the issuance of 2021 All-Source Request for Proposals (“RFP”).
b. The constraints of the transmission system external to the IPC service territory
also referenced in the Company’s NOI.
RESPONSE TO REQUEST NO. 18: The decision to update the L&R and
associated capacity deficiency date filed in Case No. IPC-E-21-09 is ultimately a decision
for the Commission to make in the case. Factors that influence the Company’s L&R are
never static, which can bring about a certain “regulatory lag” in any price setting processes
that rely on a prior Integrated Resource Plan (“IRP”) for inputs. Adjustments to correct for
the impacts of any such lag effects in this case should be carefully considered to ensure
that those adjustments result in fair prices for both third-party resource developers and
the retail customers that pay the associated cost.
a. Idaho Power’s current forecast of peak loads between 2021 and 2025 has not
increased as compared to the peak load forecast used in the 2019 IRP. While
it is true that load growth is contributing to the capacity deficiencies referenced
in the NOI, the growth is not expected to occur at a higher level than forecast
in the Company’s most recently acknowledged IRP. Because peak load growth
is not a driver of the change in the deficiency dates between the 2019 IRP and
IDAHO POWER COMPANY’S RESPONSE TO THE AMENDED THIRD PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 3
those mentioned in the NOI, it should not be considered as an L&R input to be
updated in Case No. IPC-E-21-09.
b. The Company acknowledges that there have been recent changes in the
transmission markets reducing transmission capacity availability as compared
to the 3rd party-transmission assumptions developed for the 2019 IRP.
Specifically, other transmission provider’s systems are becoming more
constrained, such that transmission capacity on their systems that may
historically have been regularly available for purchase by the Company to
import energy to serve load on a short-term basis is no longer available. The
Company further acknowledges that those changes may warrant consideration
in this case. However, the Company does not take a position in this response
as to whether, or not, such changes should be reflected in the capacity
deficiency date at issue in this case.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE AMENDED THIRD PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 4

REQUEST NO. 19: Are there any recently signed transmission or firm energy
contracts that are not included in the Company’s filed L&R or in the L&R provided in
response to Staff Production Request No. 17? If so, please list and describe these
contracts. Are these contracts incremental to the amount of Market Purchases in the
L&Rs or are these contracts considered already included in Market Purchases?
RESPONSE TO REQUEST NO. 19: There are no recently signed transmission
or firm energy contracts that are not included in the response to Staff Production Request
No. 17. The Market Purchases in the load and resource balance assume that all Idaho
Power transmission from the northwest set aside for load service is available. Market
Purchases already account for any potential transmission or energy contract additions
from the northwest. Transmission to southern hubs was reduced to 50 MW to account
for lack of available firm transmission on neighboring systems. There are no new signed
transmission or firm energy contracts from the south.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO THE AMENDED THIRD PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 5
REQUEST NO. 20: Please identify the amount of peak capacity that the
Company needs to acquire through the RFP broken down by the following:
a. Load Growth
b. Lack of external firm transmission capacity
c. Early exit date of Valmy Unit #2
RESPONSE TO REQUEST NO. 20: The Company’s response to this request
assumes Staff is referencing changes in the quantification of peak capacity needs that
occurred between the development of the 2019 IRP and the issuance of the recent Notice
of Intent (NOI), which may lead to a resource RFP for a new Idaho Power resource as
early as 2023. Because several changes to inputs and methodology impacted the load
and resource (L&R) balance analysis used to determine the peak capacity need
referenced in the NOI, it is not possible to isolate the impact that each change had on
peak capacity need in any given year. That said, the Company will focus the remainder
of this response on the changes in the L&R balance inputs and methodology that may
lead to the referenced resource RFP.
In addition to reductions in 3rd party transmission capacity, the L&R balance used
to inform the actions presented in the NOI also factored in a number of 2021 IRP
methodology updates, including the Effective Load Carrying Capability of solar, wind, and
demand response, as well as the 2021 IRP’s revised Loss of Load Expectation-derived
planning margin.
The following addresses factors a – c. However, a full reconciliation of the
differences between the L&R balance used as the starting point for the 2019 IRP and
IDAHO POWER COMPANY’S RESPONSE TO THE AMENDED THIRD PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 6
L&R balance used to inform the actions detailed in the NOI will be provided as a
supplement to this request once the Company completes the reconciliation.
a. Load Growth – The Company’s current load growth estimates are similar to the
estimates from the 2019 IRP, and therefore did not materially contribute to
changes in peak capacity need at issue in the NOI. Please refer to the Company’s
response to Staff Request No. 25 for the most recent 50th percentile load forecast.
b. Between the L&R balance for the 2019 IRP and L&R balance used to inform the
actions detailed in the NOI, the assumption for external transmission from southern
market hubs was reduced by 310 MW from 360 MW to 50 MW.
c. The L&R balance used to inform the actions detailed in the NOI assumed Valmy
Unit 2 will remain in service until the end of 2025 - the same assumption used for
the L&R balance in the 2019 IRP.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE AMENDED THIRD PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 7
REQUEST NO. 21: Is the amount of peak capacity to be acquired through the
RFP for purposes of resolving the lack of external firm transmission capacity incremental
to the amount of Market Purchases in the L&R or is it considered already included in
Market Purchases?
RESPONSE TO REQUEST NO. 21: The Market Purchases in the Load and
Resource Balance assumes the amount of transmission capacity to the Northwest set-
aside on the Idaho Power system is fully available for use. Southern market transmission
assumptions were reduced to 50 MW firm to account for lack of transmission availability.
Idaho Power has an existing 50 MW transmission service reservation with PacifiCorp to
the south. If market purchases can be acquired from the south, the market transmission
assumption will increase.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE AMENDED THIRD PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 8
REQUEST NO. 22: Does the Company’s peak load forecast used in the
Company’s filing and included in response to Staff Production Request Nos. 11 and 17
include the load growth referenced in the NOI? Please explain.
RESPONSE TO REQUEST NO. 22: Yes. The load forecasts used in the
application filing and included in the response to Staff Production Requests Nos. 11 and
17 include the load growth referenced in the NOI. Changes in load forecast are not the
main driver of the NOI. The need for nearer term resources is driven by transmission
availability on neighboring systems and adjustments to the Effective Load Carrying
Capability (ELCC) of Demand Response, solar, and wind resources.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE AMENDED THIRD PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 9
REQUEST NO. 23: Please answer the following:
a. Does the Company consider the fundamentals driving the load growth
discussed in the NOI permanent or temporary? Please explain.
b. Does the Company consider the fundamentals driving constraints in the
transmission market as discussed in the NOI to be permanent or temporary?
Please explain.
c. Given the temporary or permanent nature of these two drivers, how would
the existence of a new QF avoid capacity cost for the Company.
RESPONSE TO REQUEST NO. 23:
a. The load forecast used for the Notice of Intent is intended to represent
permanent load additions.
b. The Company expects third party transmission availability to remain tight for
the foreseeable future until incremental transmission is added to the system. In
response to the increased demand for transmission, Idaho Power is reserving
transmission on neighboring systems to the Mid-C hub where available.
c. The performance of the Qualifying Facility (“QF”) during critical peak hours
would determine whether the QF could avoid capacity cost for the Company.
Any resource that can provide capacity in the net-peak hours (late afternoon
and early evening around the solar ramp) would be beneficial.
The response to this Request is sponsored by Jared Hansen, Resource Planning
Leader, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO THE AMENDED THIRD PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 10
Respectfully submitted this 25th day of June 2021.

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO THE AMENDED THIRD PRODUCTION REQUESTS OF
THE COMMISSION STAFF - 11
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this 25th day of June 2021, I served a true and correct
copy of the within and foregoing IDAHO POWER COMPANY’S RESPONSE TO THE
AMENDED THIRD PRODUCTION REQUESTS OF THE COMMISSION STAFF upon the
following named parties by the method indicated below, and addressed to the following:

Matt Hunter
Deputy Attorney General
Idaho Public Utilities Commission
Po Box 83720
Boise, Idaho 83720-0074

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Christy Davenport, Legal Assistant